Anti-money laundering (AML) frameworks are typically designed with banks in mind, yet the duty to report large cash payments reaches far beyond traditional financial institutions. Car dealerships, jewellers, lawyers, estate agents and travel firms can all incur a federal filing obligation the instant a customer pays more than $10,000 in cash.
According to Alessa, Form 8300, the Report of Cash Payments Over $10,000 Received in a Trade or Business, is jointly issued by the Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN). Ironically, the businesses least likely to see themselves as subject to AML rules are often the ones most at risk of overlooking it.
The obligation applies to any person engaged in a trade or business, whether an individual, corporation, partnership, association, trust or estate, that receives more than $10,000 in cash in the course of trading.
Unlike Currency Transaction Reports (CTRs), which are filed by banks and credit unions, Form 8300 targets businesses accepting large cash sums from customers. Typical filers include sellers of jewellery, furniture, boats and cars, as well as pawnbrokers. Crucially, a firm does not need to be cash-heavy to be caught. A single large payment is sufficient.
The threshold covers individual transactions and two or more related ones. Payments made within 24 hours are presumed connected and must be aggregated, while those spread further apart still count if the business knows, or ought to know, they form part of a series. The definition of cash is also wider than banknotes.
It encompasses US and foreign coins and currency, plus cashier’s cheques, money orders and traveller’s cheques worth $10,000 or less when used in designated reporting transactions or to sidestep reporting.
Timing is strict. Firms have 15 days from receipt of a reportable payment to file, and where staggered payments push a running total past $10,000, the clock starts when the threshold is crossed.
Since 1 January 2024, businesses already required to e-file returns such as Forms 1099 or W-2 must submit Form 8300 electronically via FinCEN’s BSA E-Filing System. Filers must also send a written statement to each named individual by 31 January the following year, except where the form is filed voluntarily to flag suspicious sub-threshold activity, in which case the filing remains confidential.
Casinos highlight how the two regimes overlap. Larger operators file CTRs for gaming activity but must still submit Form 8300 for non-gaming cash receipts, such as restaurant or retail spending on site.
Splitting payments to avoid the threshold, known as structuring, is a federal crime in its own right. Detecting it requires pattern recognition across payments and time.
Because Form 8300 is so often viewed as a tax form rather than a compliance duty, it slips through the cracks. Firms accepting large cash sums, even occasionally, need a documented process and case management tools that track intake and filing status in one place.
Read the full Alessa post here.
Copyright © 2026 RegTech Analyst
Copyright © 2026 RegTech Analyst
